Aikens v. Banana Republic, Inc.
Rehnee Aikens, a former sales associate and stockroom manager at Banana Republic, filed a discrimination lawsuit under the Americans with Disabilities Act (ADA) and Title VII of the Civil Rights Act of 1964, claiming handicap and race discrimination, and constructive discharge. Aikens, who suffers from macular degeneration, alleged demotion when her job classification was corrected from assistant manager to stock person, which resulted in a loss of incentive bonuses. She also claimed constructive discharge due to intolerable working conditions and racial discrimination. The court granted summary judgment in favor of Banana Republic, finding that Aikens' ADA claims were not cognizable as the alleged demotion occurred before the ADA's effective date. Furthermore, Aikens failed to establish a prima facie case for handicap or race discrimination, lacked evidence of intolerable working conditions for constructive discharge, and failed to mitigate her damages by not seeking new employment.